- Missing Engine Parameter Records Lead to NOx Non-Compliance.
- EGR and SCR Issues Continue to Appear in PSC Checks.
- Fuel Sulphur Checks and Change-Over Errors Remain Widespread.
Ships are required to have valid EIAPP Certificates and NOx Technical Files for all certified engines. Spare parts, such as fuel injectors and pumps, need to match the ID numbers specified in the technical file. If the vessel relies on direct measurement or monitoring, it must have an approved Onboard Monitoring Manual on board, reports IR Class.
Engine Parameter Records
For ships using the Engine Parameter Check method, it’s essential to keep:
- A Record Book of Engine Parameters
- An approved list of engine parameters or load-dependent settings
- Technical documentation for any modifications made
All component ID numbers that impact NOx emissions, like injectors, pumps, pistons, turbochargers, coolers, and camshafts, must align with the NOx Technical File and EIAPP.
Approved Method Requirements
Engines exceeding 5,000 kW and with a cylinder volume of ≥90 L/cyl on ships built between 1990 and 1999 must adhere to Tier I, provided an approved method is certified. Section 2.2.1 of the vessel’s IAPP Supplement should accurately reflect the specific status of the ship.
EGR Systems
For ships equipped with EGR systems, they must:
- Comply with bleed-off water discharge standards
- Have an approved EGR manual and an EGR Record Book on board
- Maintain valid type-approval certificates and manuals for the 15-ppm OCM
EGR or SCR Before Entering NOx ECAs
Ships that cannot meet Tier III standards before entering a NOx ECA must promptly inform the relevant coastal State(s) and the Administration.
Engine Tier Status in Logbooks
The tier and operational status of engines certified for Tier II/Tier III should be recorded every time the vessel enters or exits a NOx ECA, including the date, time, and vessel position.
Fuel Sulphur Limits and Change-Over
Sulphur limits are as follows:
- 0.50% outside SOx ECAs
- 0.10% inside SOx ECAs (including the Baltic, North Sea, Mediterranean, NA, US Caribbean, and starting March 1, 2026: Canadian Arctic & Norwegian Sea)
- In EU ports: 0.10% while at berth.
Vessels using different fuels must have a written procedure for changing over. All volumes, dates, times, and positions related to change-over operations must be logged in approved books, whether in paper or electronic format.
Alternative SOx Compliance – EGCS
When it comes to Alternative SOx Compliance with EGCS, ships need to have certificates approved by the administration, an EGCS Record Book, and keep thorough documentation to show they’re in compliance.
Incinerators on board must be type-approved, and it’s essential to have the official operating manual readily available on the ship.
Bunker Delivery Notes (BDNs)
They should clearly state the sulphur content, flashpoint, and include a compliance declaration from the supplier. Electronic BDNs are fine as long as they meet the requirements. For IEEC and Carbon Reporting Compliance, ships are required to have a valid Statement of Compliance regarding fuel-oil consumption and CII rating, along with a current IEEC and SEEMP.
Owners and managers must check these details and promptly address any issues they find, using the provided guidance.
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Source: IR Class
